Lance v. Coffman

In Lance v. Coffman, 549 U.S. 437 (2007) (per curiam), the U.S. Supreme Court rejected a generalized lawsuit by four citizens of Colorado against redistricting after the issue had already been fully litigated by state authorities.

Underlying Lance v. Coffman was a prior lawsuit by Colorado’s attorney general, who filed an original action in the Colorado Supreme Court to enjoin Colorado’s secretary of state from implementing a new redistricting plan, and the Colorado General Assembly intervened in the action to defend its redistricting plan. The Colorado Supreme Court granted the injunction by holding that “judicially-created districts are just as binding and permanent as districts created by the General Assembly,” and that the court-drawn plan must remain in effect until the next decennial census. People ex rel. Salazar v. Davidson, 79 P. 3d 1221, 1231 (2003), cert. denied, 541 U.S. 1093 (2004). The Colorado Supreme Court then held that this result does not violate the Elections Clause of the U.S. Constitution. 79 P. 3d, at 1232. It was only after that full judicial review and resolution of the issue that four residents of Colorado sued to challenge the redistricting again, and it was that lawsuit which the U.S. Supreme Court dismissed for lack of standing. Lance v. Coffman, 549 U.S. 437, 438 (2007) (“Immediately after Salazar was decided, four Colorado citizens -- none of whom had participated in Salazar -- filed the instant action in Federal District Court.”).